OMB approves these standard forms for 18 months subject to the conditions outlined below. OMB fully expects that over the next 18 months OPM will consult with other agencies and carefully revise the forms accordingly.
1. Due to technical obstacles, OPM has not provided OMB with updated copies of the forms that include the changes that have been made as a result of public comments and OMB review. OPM will submit a revised copy of the forms with the agreed-upon changes to OMB (via a nonmaterial/ nonsubstantive change sheet) within three months of receiving clearance.
2. OPM will not proceed with the revised routine uses on the draft forms. OMB approves these forms on the condition that OPM revise the draft forms to include the routine uses on the previously-approved version of the forms (last revised 9/95), rather than the routine uses proposed on the draft forms. OPM will revise the routine uses for the next clearance period consistent with #3 below.
3. OMB issued a data call and invited comments from agencies on the Privacy Act routine uses included on these forms. Specifically, OMBÂs request solicited comment on whether the routine uses sufficiently cover the disclosures that OPM makes to agencies and other affected parties, whether these routine uses would negatively affect the business processes of the agencies, and whether there are additional routine uses that OPM should consider in future revisions. OPM will work together with OMB to determine the best process for revising the Privacy Act routine uses included on the forms to capture the routine uses across the Federal government (i.e., a working group involving both OPM and OMB).
4. The general authorization for the release of information on the SF-86 allows the investigative agency access to that individualÂs information for a period of up to five years. Ongoing access to some of this information for monitoring purposes is clearly envisioned by E.O. 12968. Within six months of approval, OPM will submit to OMB a document outlining the legal authority for accessing the types of information identified in the general release and the authorized duration for each. Within one month of submitting this document to OMB, OPM will follow-up by submitting a separate document to OMB that identifies the policy rationale for continuously collecting each type of information.
5. OPM is preparing a credit release for this form to comply with the Fair Credit Reporting Act (FCRA). OPM will continue to work on this release and will submit it for OMB review with the next full submission of this package in 18 months. OPM will conduct the appropriate consultation with the FTC, the agency responsible for FCRA oversight, prior to submitting the release for OMB approval.
6. Prior to resubmission of this form for OMB approval, OPM will re-examine the appropriateness of its burden estimates for completing these forms. OPM will break out burden for each form (SF 85, SF 85P, SF 85PS, SF 86, SF 86A, and SF 86C) according to the following factors: paper vs. electronic filers, first-time vs. repeat filers, and any other factors OPM believes to be relevant to response time. OMB expects that OPM will consult with 9 or fewer potential respondents (not OPM employees) in preparing a revised estimate.
7. OPM will consult with affected agencies to determine whether the addition of an ÂAgency Use Only block for military records would cause undue burden or whether it would add significant value. In reporting back to OMB on this issue when the form is resubmitted for OMB approval, OPM will provide a written response that includes not only the agencyÂs analysis of this issue, but also a summary of the outreach conducted on this issue.
8. On the SF 86, Question 20A (Foreign Financial Interests) requires respondents to report substantial foreign financial interests. OPM has not provided guidance to respondents on what dollar threshold would constitute a Âsubstantial interest. Absent a clear, uniform government-wide standard, reciprocity is jeopardized. OPM will work together with OMB to determine the best process for setting a threshold for substantial foreign financial interests (i.e., a working group involving both OPM and OMB).
9. On the SF 86, OPM will consider revising Question 27 (Use of Information Systems) so that the question limits respondent burden and maximizes the utility of the information collected. OMB does not consider it efficient to list the guidelines in the form of questions for these criteria; rather we strongly encourage OPM to tailor the questions to harvest relevant and material responses.
10. OPM will consult with relevant agencies regarding how these forms are used for HSPD-12 investigations and will, upon resubmission, report to OMB as to whether any changes/ additions are necessary for the forms to be used for HSPD-12 purposes.
table that charts list comparision
Inventory as of this Action
Requested
Previously Approved
09/30/2008
36 Months From Approved
03/31/2007
276,200
0
252,310
366,200
0
314,555
0
0
0
The forms are used to initiate national security and suitability investigations.
On behalf of this Federal agency, I certify that the collection of information encompassed by this request complies with 5 CFR 1320.9 and the related provisions of 5 CFR 1320.8(b)(3).
The following is a summary of the topics, regarding the proposed collection of information, that the certification covers:
(i) Why the information is being collected;
(ii) Use of information;
(iii) Burden estimate;
(iv) Nature of response (voluntary, required for a benefit, or mandatory);
(v) Nature and extent of confidentiality; and
(vi) Need to display currently valid OMB control number;
If you are unable to certify compliance with any of these provisions, identify the item by leaving the box unchecked and explain the reason in the Supporting Statement.
Questionnaires and Supplemental Form for National Security, Public Trust, and Non-sensitive Positions